In terms of allocating expenses between rental use and personal use, the IRS method of allocation tends to allocate more expenses to personal use than does the Tax Court method of allocation.

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The IRS Method uses the total personal and rental days as the denominator whereas the tax court method uses the entire year. The tax court method results in a smaller percentage allocated to rental days and larger percentage allocated to personal use.

In Terms of Allocating Expenses Between Rental Use and Personal